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Individual entrepreneur Yana Pushkareva Personal Data Processing Policy
1. What does this document regulate?
1.1. This Policy (hereinafter referred to as the "Policy") defines the policy of the personal data operator — Individual entrepreneur Yana Pushkareva, address: Batumi, Parnavaz Mepe 60 (hereinafter referred to as the "Operator") regarding the processing of personal data collected using the website https://ravi.starterapp.ru (hereinafter referred to as the "Site"), and contains information on the requirements implemented by the Operator for the protection of such personal data.
1.2. Personal data is processed in confidentiality. The Operator does not disclose to third parties or distribute personal data of personal data subjects without the consent of the personal data subject, unless otherwise provided by the legislation of Georgia.
2. Rights and obligations of the Personal Data Operator and personal data subjects
2.1. The personal data operator of subjects has the following rights:
1. What does this document regulate?
1.1. This Policy (hereinafter referred to as the "Policy") defines the policy of the personal data operator — Individual entrepreneur Yana Pushkareva, address: Batumi, Parnavaz Mepe 60 (hereinafter referred to as the "Operator") regarding the processing of personal data collected using the website https://ravi.starterapp.ru (hereinafter referred to as the "Site"), and contains information on the requirements implemented by the Operator for the protection of such personal data.
1.2. Personal data is processed in confidentiality. The Operator does not disclose to third parties or distribute personal data of personal data subjects without the consent of the personal data subject, unless otherwise provided by the legislation of Georgia.
2. Rights and obligations of the Personal Data Operator and personal data subjects
2.1. The personal data operator of subjects has the following rights:
- to receive reliable information from the personal data subject regarding the personal data provided by him;
- to request from the personal data subject timely clarification of the personal data provided.
2.2. The operator of personal data of the subjects undertakes to:
- process personal data in the manner prescribed by the current legislation of Georgia;
- consider the requests of the subject of personal data (his/her legal representative) on issues of processing personal data and provide reasoned responses within ten working days from the date of receipt of the relevant request;
- provide the subject of personal data (his/her legal representative) with the opportunity of free access to his/her personal data;
- take measures to clarify, destroy the personal data of the subject of personal data in connection with his/her (his/her legal representative’s) appeal with legal and justified demands, as well as upon achieving the purposes of processing personal data;
- organize the protection of personal data in accordance with the requirements of the legislation of Georgia;
- bear other obligations in accordance with the requirements of the legislation of Georgia.
2.3. Rights of personal data subjects:
- to receive information about their personal data processed by the Operator by sending a written request to the postal or e-mail address specified on the Website on the "Offer" page;
- to gain access to their personal data, except for cases stipulated by law;
- to clarify their personal data, to request their blocking or destruction in cases where the personal data is incomplete, outdated, inaccurate, illegally obtained or is not necessary for the stated purpose of processing by sending a written request to the postal or e-mail address specified on the Website on the "Offer" page;
- to revoke consent to the processing of personal data by sending a written request to the postal or e-mail address specified on the Website on the "Offer" page;
- to exercise other rights stipulated by the legislation of Georgia.
2.4. Obligations of personal data subjects:
- to provide the Operator with only reliable data and information;
- to inform the Operator about clarification (update, change) of their personal data.
3. Whose and what personal data is processed
3.1. The Operator processes personal data of the following categories of subjects whose personal data may be collected by the Operator using the Site:
3.1. The Operator processes personal data of the following categories of subjects whose personal data may be collected by the Operator using the Site:
- unregistered users;
- registered users;
- recipients of goods and services sold by the Operator (who are not registered users).
3.2. The Operator's processing of personal data of other categories of personal data subjects is regulated by other local acts of the Operator. The processed personal data of unregistered and registered users of the Site, as well as recipients of goods and services sold by the Operator, include all information provided to the Operator by users using the Site, including by filling in the relevant fields of the personal data subject's data on the Site, including:
- last name, first name, patronymic;
- mobile phone number;
- e-mail address;
- delivery address of goods sold by the Operator;
- order history sold by the Operator;
- history of requests and views on the Site and its services;
- other information (the list provided may be shortened or expanded depending on the specific case and purposes of processing).
4. For what purposes are personal data processed
4.1. The Operator will process the personal data of unregistered users for the following purposes:
1) their use of the Site, which includes:
4.1. The Operator will process the personal data of unregistered users for the following purposes:
1) their use of the Site, which includes:
- providing users with reference information about the goods and services sold by the Operator,
- providing users with consultations on issues related to the goods and services sold by the Operator, user support,
- improving the usability of the Site;
2) promoting the goods and services sold by the Operator by demonstrating the goods and services sold by the Operator on the Site.
To achieve the above purposes, the Operator processes the following personal data of registered users:
To achieve the above purposes, the Operator processes the following personal data of registered users:
- history of requests and views on the Site and its services;
- other information that the user deems necessary to provide.
4.2. The Operator will process the personal data of registered users for the following purposes:
1) their use of the Site, which includes:
1) their use of the Site, which includes:
- communication with the Operator,
- providing users with reference information about the goods and services sold by the Operator,
- providing users with advice on issues related to the goods and services sold by the Operator, user support,
- improving the usability of the Site;
2) promoting the goods and services of the Operator by making direct contacts with users;
3) delivery of goods sold by the Operator, which includes:
3) delivery of goods sold by the Operator, which includes:
- communication with the Operator,
- providing users with information about the upcoming delivery of goods sold by the Operator,
- providing recipients of goods and services sold by the Operator with advice on issues related to the delivery of goods sold by the Operator, support for recipients of goods and services sold by the Operator.
To achieve the above purposes, the Operator processes the following personal data of registered users:
- last name, first name, patronymic;
- mobile phone number;
- e-mail address;
- delivery address of goods sold by the Operator;
- history of orders sold by the Operator;
- history of requests and views on the Site and its services;
- other information (the above list may be shortened or expanded depending on the specific case and purposes of processing).
4.3. The Operator will process the personal data of recipients of goods and services sold by the Operator for the purpose of the latter delivering goods sold by the Operator, which includes:
- communication with the Operator,
- providing users with information about the upcoming delivery of goods sold by the Operator,
- providing recipients of goods and services sold by the Operator with consultations on issues related to the delivery of goods sold by the Operator, and support for recipients of goods and services sold by the Operator.
In order to achieve the above purposes, the Operator processes the following personal data of recipients of goods and services sold by the Operator:
- last name, first name, patronymic;
- mobile phone number;
- e-mail address;
- delivery address of goods sold by the Operator;
- other information (the above list may be shortened or expanded depending on the specific case and the purposes of processing).
5. How personal data is processed
5.1. The operator may process personal data using automation tools or without using such tools by collecting, recording, systematizing, accumulating, storing, clarifying (updating, changing), retrieving, using, transferring (providing, accessing), blocking, deleting, destroying.
5.2. The operator has the right to transfer personal data to third parties or entrust the processing of personal data to third parties if this is necessary to achieve the purpose of their processing in accordance with this Policy, as well as in cases stipulated by the current legislation of Georgia on personal data.
5.3. The operator will process personal data no longer than required by the purpose of their processing, unless other terms are stipulated by the current legislation of Georgia on personal data.
6. How personal data is protected
6.1. The operator takes a responsible approach to the issue of protecting the collected personal data and implements the requirements for their protection by taking a set of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the current legislation of Georgia on personal data.
6.2. The Operator shall not be liable for the receipt of personal data by third parties by accessing the personal account of registered users. Registered users of the Site are obliged to independently ensure the safety of data for access to their personal account.
5.1. The operator may process personal data using automation tools or without using such tools by collecting, recording, systematizing, accumulating, storing, clarifying (updating, changing), retrieving, using, transferring (providing, accessing), blocking, deleting, destroying.
5.2. The operator has the right to transfer personal data to third parties or entrust the processing of personal data to third parties if this is necessary to achieve the purpose of their processing in accordance with this Policy, as well as in cases stipulated by the current legislation of Georgia on personal data.
5.3. The operator will process personal data no longer than required by the purpose of their processing, unless other terms are stipulated by the current legislation of Georgia on personal data.
6. How personal data is protected
6.1. The operator takes a responsible approach to the issue of protecting the collected personal data and implements the requirements for their protection by taking a set of measures necessary and sufficient to ensure the fulfillment of obligations stipulated by the current legislation of Georgia on personal data.
6.2. The Operator shall not be liable for the receipt of personal data by third parties by accessing the personal account of registered users. Registered users of the Site are obliged to independently ensure the safety of data for access to their personal account.
7. Consent to the processing of personal data and applicable clauses
7.1. The Site User voluntarily, of his own free will and in his own interests provides his personal data to the Operator.
7.2. By accepting the terms of this Policy, the Site User hereby confirms that the personal data provided by him is reliable. The Operator assumes that the Site User provides reliable personal data and keeps it up to date.
7.3. By filling in the data fields provided on the Site, the Site User accepts this Policy and gives his consent to the processing of his personal data in the manner and on the terms specified in this Policy.
7.4. By filling in the data fields in relation to recipients of goods and services sold by the Operator, the Site User guarantees the consent of such recipients of goods and services to the processing of their personal data in the manner and on the terms specified in this Policy. In this case, the user of the Site also undertakes to notify such recipients of goods and services sold by the Operator about the transfer of their personal data to the Operator and guarantees such notification.
7.5. By accepting the terms of this Policy, the user of the Site confirms that he is aware of his rights and obligations stipulated by the current legislation of Georgia on personal data, in particular, the right to access his personal data, to revoke his consent.
7.6. The condition for termination of the processing of personal data is the achievement of the purposes of processing personal data, expiration of the consent or revocation of the consent of the subject of personal data to the processing of his personal data, as well as the detection of unlawful processing of personal data. The subject of personal data may revoke consent to the processing of his personal data by sending a written notice to the e-mail address specified on the Site on the "Offer" page.
7.7. If the user of the Site does not intend to provide personal data or does not accept this Policy, then he must stop using the Site, in which case the Operator will not be able to provide the user with the use of the Site.
7.1. The Site User voluntarily, of his own free will and in his own interests provides his personal data to the Operator.
7.2. By accepting the terms of this Policy, the Site User hereby confirms that the personal data provided by him is reliable. The Operator assumes that the Site User provides reliable personal data and keeps it up to date.
7.3. By filling in the data fields provided on the Site, the Site User accepts this Policy and gives his consent to the processing of his personal data in the manner and on the terms specified in this Policy.
7.4. By filling in the data fields in relation to recipients of goods and services sold by the Operator, the Site User guarantees the consent of such recipients of goods and services to the processing of their personal data in the manner and on the terms specified in this Policy. In this case, the user of the Site also undertakes to notify such recipients of goods and services sold by the Operator about the transfer of their personal data to the Operator and guarantees such notification.
7.5. By accepting the terms of this Policy, the user of the Site confirms that he is aware of his rights and obligations stipulated by the current legislation of Georgia on personal data, in particular, the right to access his personal data, to revoke his consent.
7.6. The condition for termination of the processing of personal data is the achievement of the purposes of processing personal data, expiration of the consent or revocation of the consent of the subject of personal data to the processing of his personal data, as well as the detection of unlawful processing of personal data. The subject of personal data may revoke consent to the processing of his personal data by sending a written notice to the e-mail address specified on the Site on the "Offer" page.
7.7. If the user of the Site does not intend to provide personal data or does not accept this Policy, then he must stop using the Site, in which case the Operator will not be able to provide the user with the use of the Site.
8. What other data may be processed
8.1. The Operator may collect information about users' visits to the Site without the users themselves providing the relevant information. Such information may be obtained using various methods, means and tools of Internet statistics and settings (in particular, Cookie files, Yandex.Metrica service, Google Analytics). The Operator may use such methods, means and tools to promote the goods and services sold by the Operator, provide information about the goods and services sold by providing targeted advertising, and improve the usability of the Site by creating profiles of registered users. However, such methods, means and tools are not used to identify unregistered users.
8.2. If a Site user does not agree to Cookie files being saved on his device, he can independently disable this option in the browser settings. Saved Cookie files can also be deleted at any time in the browser system settings. The Site user can change the browser settings to accept or reject by default all Cookie files or Cookie files from certain websites, including the Site.
8.3. Disabling some Cookies may make it impossible to use certain sections or functions of the Site.
8.4. If the Site user does not agree with the use of methods, means and tools of Internet statistics and settings, he/she must stop using the Site, in which case the Operator will not be able to provide the user with the use of the Site.
8.1. The Operator may collect information about users' visits to the Site without the users themselves providing the relevant information. Such information may be obtained using various methods, means and tools of Internet statistics and settings (in particular, Cookie files, Yandex.Metrica service, Google Analytics). The Operator may use such methods, means and tools to promote the goods and services sold by the Operator, provide information about the goods and services sold by providing targeted advertising, and improve the usability of the Site by creating profiles of registered users. However, such methods, means and tools are not used to identify unregistered users.
8.2. If a Site user does not agree to Cookie files being saved on his device, he can independently disable this option in the browser settings. Saved Cookie files can also be deleted at any time in the browser system settings. The Site user can change the browser settings to accept or reject by default all Cookie files or Cookie files from certain websites, including the Site.
8.3. Disabling some Cookies may make it impossible to use certain sections or functions of the Site.
8.4. If the Site user does not agree with the use of methods, means and tools of Internet statistics and settings, he/she must stop using the Site, in which case the Operator will not be able to provide the user with the use of the Site.
9. Destruction of personal data
9.1. Upon achievement of the purposes of personal data processing, expiration of the consent to the processing of personal data, as well as in the event of withdrawal of the consent to the processing by the subject of personal data, the personal data are subject to destruction, unless:
otherwise provided by the agreement to which the subject of personal data is a party, beneficiary or guarantor;
otherwise provided by another agreement between the operator and the subject of personal data.
9.2. If the processing of personal data is carried out by the Operator without the use of automation tools, the document confirming the destruction of the personal data of the subjects of personal data is the act of destruction of personal data.
9.3. If the processing of personal data is carried out by the Operator using automation tools, the documents confirming the destruction of the personal data of the subjects of personal data are the act of destruction of personal data and the unloading from the event log in the personal data information system.
9.4. If the personal data is processed by the Operator simultaneously with the use of automation tools and without the use of automation tools, the documents confirming the destruction of personal data of personal data subjects are the act of destruction of personal data and the unloading from the event log in the personal data information system.
9.5. The act of destruction of personal data and the unloading from the log shall be stored for 3 years from the date of destruction of personal data.
10. Final Provisions
10.1. This Policy is subject to change or addition in cases of making appropriate changes or additions to the current legislation of Georgia on personal data, and can also be changed at any time at the discretion of the Operator. The current version of the Operator's Policy is always available for viewing by an unlimited number of people on the Site.
10.2. All relations involving the Operator, related to the processing and protection of personal data and not directly reflected in this Policy, are regulated in accordance with the provisions of the current legislation of Georgia on personal data.
10.3. Date of last Policy update: 10.10.2023
9.1. Upon achievement of the purposes of personal data processing, expiration of the consent to the processing of personal data, as well as in the event of withdrawal of the consent to the processing by the subject of personal data, the personal data are subject to destruction, unless:
otherwise provided by the agreement to which the subject of personal data is a party, beneficiary or guarantor;
otherwise provided by another agreement between the operator and the subject of personal data.
9.2. If the processing of personal data is carried out by the Operator without the use of automation tools, the document confirming the destruction of the personal data of the subjects of personal data is the act of destruction of personal data.
9.3. If the processing of personal data is carried out by the Operator using automation tools, the documents confirming the destruction of the personal data of the subjects of personal data are the act of destruction of personal data and the unloading from the event log in the personal data information system.
9.4. If the personal data is processed by the Operator simultaneously with the use of automation tools and without the use of automation tools, the documents confirming the destruction of personal data of personal data subjects are the act of destruction of personal data and the unloading from the event log in the personal data information system.
9.5. The act of destruction of personal data and the unloading from the log shall be stored for 3 years from the date of destruction of personal data.
10. Final Provisions
10.1. This Policy is subject to change or addition in cases of making appropriate changes or additions to the current legislation of Georgia on personal data, and can also be changed at any time at the discretion of the Operator. The current version of the Operator's Policy is always available for viewing by an unlimited number of people on the Site.
10.2. All relations involving the Operator, related to the processing and protection of personal data and not directly reflected in this Policy, are regulated in accordance with the provisions of the current legislation of Georgia on personal data.
10.3. Date of last Policy update: 10.10.2023